On November 21, 2019, U.S. Citizenship & Immigration Services (USCIS) published a new edition of the form I-924A, Annual Certification of Regional Center. According to the USCIS website, all Regional Centers who are required to file an I-924A for FY2019 will be required to use the new form starting December 6, 2019 if said Regional Center has not already filed its FY2019 I-924A.
Notable changes to the form are in Part 5, Items 1-4 (“Information About the Regional Center’s Operations – Aggregate Capital Investment and Job Creation”). Information about these changes can be reviewed in the instructions document provided by USCIS on the I-924A webpage along with the updated form.
Below is the verbatim text for Part 5, Items 1-4 from the I-924A instructions document:
Part 5. Information About the Regional Center’s Operations
Item Numbers 1. – 4. Aggregate Capital Investment and Job Creation. Provide the following information, in aggregate, from all sponsored projects:
- EB-5 investor capital invested through the regional center;
- Non-EB-5 capital invested through the regional center;
- New direct, indirect, and/or induced jobs created through the regional center; and
- Jobs maintained for EB-5 purposes through the regional center by investment into “troubled businesses” (if applicable).
NOTE: When reporting job creation, the numbers should reflect the aggregate direct, indirect, and/or induced jobs that have actually been created by all sponsored projects to date, regardless of whether any petitioners have independently claimed credit for such jobs on any Form I-526, Immigrant Petition by Alien Investor or Form I-829, Petition by Investor to Remove Conditions. This calculation should employ the same economic methodology identified when the project was first submitted to USCIS with Form I-924, Application For Regional Designation Center Under the Immigrant Investor Program, with an exemplar project or a Form I-526 petition. In cases where a current project is different than what was contemplated in Form I-924 or Form I-526, the job creation calculation should employ the intended methodology for related Form I-829.
Where utilized job creation methodologies use inputs of expenditures, revenues, and/or direct jobs, the reported aggregate jobs created should be the result of those job creating inputs to date. Include a description which explains the prorated inputs and job creation calculations in relation to the total jobs expected to result from the project.
If there is more than one project sponsored through a regional center or if a particular project’s jobs were not all created during the Federal fiscal year covered by the form, use the space provided in Part 11. Additional Information to report the number of jobs created by Federal fiscal year for each sponsored project.
Regional Centers should contact their legal counsel for questions regarding their specific filing requirements.
